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Environmental & Social Review Summary
Project Number
31059
Company Name
Canopus Holding
Date ESRS Disclosed
Dec 21, 2011
Country
Brazil
Region
Latin America and the Caribbean
Last Updated Date
Apr 10, 2024
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Apr 19, 2012
Signed : Sep 4, 2012
Invested : Dec 27, 2012
Sector
Construction and Real Estate
Industry
Tourism, Retail and Property
Department
Regional Industry - MAS LAC
Project Description
The project is to support Grupo Canopus (“Canopus” or the “Company”), to expand its focus on low-income housing developments under the Minha Casa Minha Vida or any follow on governmental program. Canopus, one of the largest real estate developers and construction companies in the state of Minas Gerais, Brazil, has invited IFC to make an equity investment to support its corporate capital expenditure plan for the expansion of its footprint in the affordable housing segment specially in the 0 to 10 minimum wages segment (including in underdeveloped regions such as Brazilian North and Northeast), as well as the consolidation of its current position in the mid-high income and commercial segments (the “Project”). The low income housing segment is managed by the Company under the brand name Emcasa.
Overview of IFC's Scope of Review
IFC’s review included visits to Grupo Canopus’ (“Canopus” or the “Company”) administrative offices in Belo Horizonte, State of Minas Gerais, Brazil, as well as field visits to projects under construction at the time of the appraisal. IFC met and interviewed key staff (corporate and operational management; new projects development; occupational health and safety engineers; and human resources management) and reviewed numerous, relevant internal documents and records surrounding the Sponsor’s environmental and social (E&S) performance. Among others, these included environmental licenses for a representative set of projects; health and safety procedures; employee manuals defining the Sponsor’s human resources policy; sample employment contracts; and presentation materials about the Sponsor business activities. IFC staff also conducted inspections of representative projects under construction including: a low income housing project in the State of Minas Gerais; a middle income residential project near Campinas, State of Sao Paulo; and a high-rise commercial office building near the City of Sao Paulo.
E & S Project Categorization and Applicable Standard
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
PS 1: Social and Environmental Assessment and Management Systems;
PS 2: Labor and Working Conditions;
PS 3: Pollution Prevention and Abatement;
PS 4: Community Health, Safety and Security;
PS 5: Land Acquisition and Involuntary Resettlement; and
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management.
PS 7: Indigenous Peoples impacts are not expected as the development of new projects targets urban and peri-urban settings that are also not classified as indigenous lands. PS 8: Cultural Heritage impacts are not expected as developments are not typically situated in areas of archeological or historical significance and as Brazilian regulations already strictly govern the management of chance finds in construction activities.
PS 1: Social and Environmental Assessment and Management Systems;
PS 2: Labor and Working Conditions;
PS 3: Pollution Prevention and Abatement;
PS 4: Community Health, Safety and Security;
PS 5: Land Acquisition and Involuntary Resettlement; and
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management.
PS 7: Indigenous Peoples impacts are not expected as the development of new projects targets urban and peri-urban settings that are also not classified as indigenous lands. PS 8: Cultural Heritage impacts are not expected as developments are not typically situated in areas of archeological or historical significance and as Brazilian regulations already strictly govern the management of chance finds in construction activities.
This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because Sponsor’s business in residential and commercial real estate development presents a limited number of specific environmental and social impacts which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Furthermore, the Sponsor is presently demonstrating the ability to effectively manage potential environmental and social risks from its business activities through the application of national legislation which will be complemented with additional actions defined as part of IFC’s investment conditions.
Environmental and Social Mitigation Measures
The followings section describes how the Sponsor does or will design and manage operations in a manner consistent with local requirements and the Performance Standards. The attached Environmental and Social Action Plan summarizes measures that the Sponsor has agreed to implement that supplement current practice.
PS1: Social and Environmental Assessment and Management Systems
- Environmental and Social Assessment – The Sponsor complies with Brazilian requirements to conduct environmental and social impact assessments of its commercial and residential developments. The stepwise licensing process depends on the nature and location of the proposed project but may include, depending on the municipal jurisdiction, a series of feasibility studies in order to obtain preliminary permits and approvals including for example: approval of architectural design, including restrictions on height, set-backs, and limits on total area of construction; authorization for removal of natural vegetation; excavation permits; construction works permits; and authorization for connection to utilities. Depending on the extent and location of the proposed project, local authorities may also require more detailed environmental and social impact assessments prior to issuing construction and operating licenses (based on the regulator’s review of project impacts and mitigation measures). These assessments may consist of formal, detailed, Environmental and Social Impact Assessment (ESIA) studies or more streamlined Simplified Environmental Reports, depending also on the complexity and size of the project. Recently enacted legislation may also require completing studies of community impacts (Estudo de Impacto de Vizinhança (EIV)), to evaluate impacts on transit, landscape, and other aspects specific to urban areas.
The Sponsor will formalize an Environmental and Social (E&S) assessment procedure to be integrated into its existing land assessment and acquisition process. The procedure will define the minimum scope of E&S impact assessment applicable to each type of project (i.e. commercial or residential in urban, peri-urban or rural areas) taking into account the level of complexity and risk of the type of project. The defined scope will help ensure an adequate level of assessment of E&S risks and impacts that is consistent with IFC’s Performance Standards and that mitigates the risk of variability in the local E&S assessment requirements.
Assessment will include consideration of aspects of IFC’s Performance Standards relevant to the individual projects, including but not limited to: (i) site-specific pollution prevention and abatement screening (such as proximity to and potential impacts upon water bodies, past use of sites and resulting legacy environmental impacts), (ii) community health, safety and security including site vulnerability to landslide or flooding, traffic impacts and their management, and compliance with established standards governing structural integrity and life and fire safety; (iii) potential economic and physical displacement associated with land acquisition; (iv) Site-specific biodiversity assessment (if applicable) and; (v) potential discovery of cultural property.
- Management Program – The Sponsor has an established corporate level human resource management and administration system and processes addressing land acquisition, product development, a technical project development, construction management and sales and marketing. Construction managers are responsible for continuous management of construction schedules, costs and contractor (and sub-contractor) performance. Environmental and social (E&S) aspects are managed primarily as defined by applicable local, state, and national legal requirements using these requirements to guide and document the E&S management program. Brazilian regulations are comprehensive and in some cases are supported by detailed technical specifications and procedures, particularly with respect to aspects of occupational health and safety (OHS). In response to these requirements, the company prepares project-specific OHS management programs (PCMATs) which identify applicable occupational hazards and provide procedures for their control. These programs are complemented by a brief OHS procedure prepared by the company.
In order to continue to effectively manage the E&S aspects of its construction activities as the company grows, the Sponsor will formalize its E&S management processes and procedures into a documented E&S management program. The program will articulate an E&S policy and will include aspects such as review of the environmental assessment documents, contracting and supervision of consultants to assist in the preparation and monitoring of environmental and social management plans, and input into construction contracts to ensure compliance with environmental permit requirements.
- Organization – Responsibility for the Sponsor’s management of environmental, social, health, safety and labor aspects is fairly decentralized and shared among various departments and individuals of the organization. The implementation of environmental management requirements related to project development and construction are currently the responsibility of the project architects who ensure that all environmental licensing requirements are met as part of new project development and who are also responsible for their implementation during the construction phase. OHS aspects are the responsibility of an Occupational Safety Engineer who oversees corporate-wide construction projects and who is supported by Occupational Safety Specialist responsible for project-level oversight of OHS matters according to Brazilian legal requirements. Community engagement activities (described under the “Client’s Community Engagement” section below) are currently managed through the Sales Department (for complaints related to clients) and by construction site managers. As previously noted, ESIAs are usually prepared by external consulting firms.
Going forward, the Sponsor will strengthen the organizational structure currently responsible for implementation of the environmental, social, and health and safety management programs, by assigning sufficient human resources to implement current and future expansion needs as defined through the development of a formal E&S management program. This will include sufficient corporate level resources to monitor the management of OHS aspects across all of the Sponsor’s construction sites, including those outside the State of Minas Gerais as well as formal assignment of responsibilities for monitoring of environmental aspects in construction projects.
- Training – Given the nature of the Sponsor’s business activities, employee training programs are focused on the prevention of OHS risks in civil construction sites. As required by Brazilian legal requirements, the Sponsor has a defined training program covering aspects such as the identification of workplace hazards; the use of personal protective equipment and collective protection equipment; machine and tool safety; fall protection; electrical and fire hazards; and the roles and responsibilities of employers and employees. The company complements the basic training program with aspects specific to the work function (for example on scaffolding procedures for those responsible for this activity). Training is required at the time of employment and at the beginning of any construction project. A training registry is maintained of all company employees.
- Monitoring – The focus of the company’s monitoring is on the occupational, health and safety (OHS) aspects associated with construction activities. This includes a registry of all accidents, including those resulting in time away from work. Accidents registered are used to calculate frequency and severity rates according to local regulatory requirements. OHS monitoring also includes entrance, exit, and periodic medical exams as defined by a legally required occupational health medical control program (PCMSO). Additionally, internal site visits of construction projects are conducted by the corporate Occupational Safety Engineer to observe adherence to OHS procedures. Going forward, the Sponsor will monitor relevant environmental indicators, for example, construction materials waste generation and recycling and other construction activity environmental indicators, as applicable. OHS monitoring will further incorporate data of subcontractor accidents occurring in the Sponsor’s construction work sites.
- Reporting – The results of OHS monitoring activities are summarized into internal reports that are shared with company management who are also kept abreast on the status of environmental licensing processes, together with general project progress reports, by the architects responsible for these activities. Going forward, the Sponsor will prepare and internally distribute corporate monitoring information of a selected set of environmental, OHS, and social indicators. The Sponsor will further prepare and externally distribute a selected set of environmental and social indicators in a location / format easily accessible to interested members of the community. This information can be included in the company’s website or as a free standing Sustainability Report.
PS2 - Labor and Working Conditions
- Human Resource Policy and Management – At the time of appraisal, the Sponsor had approximately 1,900 direct employees, less than 10% of which are administrative and managerial staff (i.e. project planning, accounting, human resources management, etc) with the reminder dedicated to construction labor in the Canopus and Emcasa operations. Although the construction labor force fluctuates from year to year depending on the number and stage of construction projects (for example, there was a registered decrease of about 900 construction workers between 2010 and 2011) , Sponsor operations have grown significantly over recent years and are expected to continue to grow given the planned business expansion activities.
The company currently communicates employee rights and responsibilities through an Internal Employment Rules Handbook (Manual do Colaborador) and through employment contracts. The Internal Employment Rules Handbook defines company policy regarding general aspects of the company’s quality assurance program; safety and hygiene; maternity leave; holidays and vacation; justified absences from work; overtime benefits; proof of salary payment; use of uniforms; rules of use of means of communication (email and telephone); OHS; employment exit process; ethics; and dismissal. Individual employment contracts further define working hours and compensation applicable to the individual. In Brazil, the Consolidated Labor Law (CLT) comprehensively defines employee rights, substantially covering all aspects of Performance Standard 2. The CLT is widely divulged through the publication of pocket handbooks and is well known among the blue collar workforce across almost all industry sectors, including construction.
Nonetheless, going forward the Sponsor will amend its Internal Employment Rules Handbook in order to ensure consistency with IFC’s Performance Standard 2 in such aspects as: permissible wage deductions; legal maximums in hours of work; entitlement to benefits; non discrimination; and employees’ right to form and join workers’ organizations of their choosing and to bargain collectively with the employer.
- Grievance Mechanism – The company employees are currently able to lodge complaints internally through the Human Resources department and Company management, and externally through the public Labor Rights system. Going forward, the company will develop and implement an employee grievance process, published as part of the Internal Employment Rules Handbook to ensure consistency with IFC’s Performance Standard 2. The grievance process will allow: (a) any employee grievance by individuals or groups (including anonymous complaints) to be presented verbally or on in writing, without the risk of reprisals; documented and reviewed by company management and subject to a timetable for formal response and resolution; (b) workers the opportunity to meet with management, accompanied by a representative or companion; and (c) an appeal mechanism. The company will make the grievance procedure available to all existing and new employees at the time of hire.
- Worker’s Organizations – IFC found no evidence that the Sponsor restricts employees’ rights to freedom of association and collective bargaining.
- Non-Discrimination and Equal Opportunity – The Sponsor’s recruitment process gives priority to internal employees and apprentices by announcing all vacancies internally for a period of 15 days before external advertisement. Vacancy announcements do not include criteria such as desired age, sex or religion of candidates, or any other criteria unrelated to an applicant’s ability to fulfill the requirements of the position.
- Protecting the Workforce –Child labor is also strictly prohibited under Brazilian law and the Sponsor routinely verifies the age of job applicants by requirement proof of working age included in the workers’ social security cards. Employment contracts and Internal Employment Rules used by Sponsor clearly do not allow for circumstances that could be construed as forced labor.
-Occupational Health and Safety – The Sponsor has an OHS management program based on specific Brazilian regulatory requirements covering health monitoring (PCMSOs), project level occupational risk prevention programs (PCMATs), and applicable technical norms such as NR-18 for occupational health and safety in the construction industry. The project specific OHS management programs (PCMATs) cover such aspects as task-based risks for site preparation; unloading of cement and construction materials; excavations; concrete forms; electrical work; and finishing, to name a few. It also includes brief, simplified, procedures for the safe use and operation of hand tools, hoists, and elevators, for work in heights (including scaffolding), and for the safe use of chemical substances. Requirements for the Sponsor to come into compliance with IFC’s OHS requirements are described above under “Performance Standard 1.”
- Non-Employee Workers – The Sponsor subcontracts additional specialized services, particularly in commercial real estate developments, for such aspects as large excavation and leveling; rock blasting; demolition of old structures; damp-proofing; electrical and mechanical installations including elevators, escalators, and fire alarm and suppression systems; and cleaning and security services. All of these activities are performed based on short-term contracts and not for the exclusivity of the Sponsor.
PS3: Pollution Prevention and Abatement:
-Effluent Management - Typically for commercial and residential developments in urban areas, effluents are discharged to municipal sewage systems. This is also the case in low income housing developments located in urban or peri-urban areas where the Sponsor installs collection networks and, where necessary sewer pump stations, in order to connect to existing collection networks sometimes leading to municipal wastewater treatment plants. The Sponsor is also involved with projects in peri-urban areas without established sewage collection networks or treatment systems. In Brazil, such developments have historically used septic-tank and leach field based sanitation treatment and disposal systems. In small (<2,000 persons) peri-urban developments, the Sponsor will continue to adopt such technology subject to local approval and unless assessment shows a particular reason not to do so.
For large-scale peri-urban housing developments where a septic tank and leach-field sanitation solution is under consideration, such a solution will only be adopted if independent technical assessment determines that such a solution will not have adverse impact on human health or the environment. Such determination will follow site specific assessment that would typically consider cumulative impacts of large numbers of leach fields through a quantitative analysis including infiltration modeling and evaluation of potential quality effects to surface water and ground water (e.g., nutrients / nitrate contamination), contaminant fate and transport study, taking account of location and characteristics of the closest sensitive receptors (including water wells or other water collection systems), assimilative capacity of the receiving water body; and uses of the receiving water body. In these large-scale peri-urban developments, unless analysis such as described above demonstrates that a septic tank and leach field technology does not have an adverse impact on human health or the environment, then the Sponsor will design and construct the development to incorporate a sewage collection network, and will construct, or cause to be constructed by others, a sewage treatment system for the development. The Sponsor indicates that under this situation, the operation and maintenance of the wastewater treatment infrastructure would be transferred to the local municipality as is the case in a low income project with 3,000 units in Santarem, State of Para, where the sewage treatment plant for the low income housing project will be transferred to the local municipal government upon completion.
In addition, in any development that utilizes a septic tank and leach field sanitation solution, such as the recently constructed project in Itaituba, State of Para, or a planned project in Gurupi, State of Tocantins, the Sponsor will educate home purchasers of the need to arrange regular servicing of septic tank systems, typically every two years. This will be done by introduction of the homeowner or homeowners’ condominium association as relevant to an approved management company or through coordination with local authorities responsible for receiving and managing septage waste.
- Wastes - During the construction of new projects, the Sponsor follows the environmental conditions of the environmental license and any other local legal requirements which include management of excavated materials from civil works site preparation (e.g. soil and rock materials); miscellaneous organic and inorganic domestic waste from work site services and offices (e.g. food, paper, and plastics); equipment shipping materials (e.g. wood crates, cardboard, etc); and construction equipment maintenance wastes (e.g. waste lubricants, used oil filters, etc), and the use of portable toilets.
- Ambient Noise – During the construction phase, ambient noise concerns are managed by proper maintenance of construction equipment exhaust noise controls and through restrictions on construction site operating hours.
- Energy Conservation – Energy conservation considerations are mainly included in the design of commercial real estate (high rise office buildings). These include energy efficient cooling systems; energy efficient lighting fixtures, including motion sensors in some common areas; and, in a recent high-rise office building, use of elevators with regenerative brake systems. In the residential segment, the Sponsor’s inclusion of energy conservation measures in the design are mainly limited to solar water heaters, although these are mainly used in the middle to high income constructions. In low income houses, this equipment is only used if Caixa, the public sector finance institution backing these projects, approves and covers the cost increase.
PS4: Community Health, Safety and Security
- Infrastructure and Equipment Safety - During the construction phase, the principal risk to health and safety of the community typically consist of traffic and pedestrian safety from the transport of construction materials, equipment, and workers to and from the construction sites and potential for structural damage to local housing located adjacent to transport routes. The Sponsor requires construction contractors to adhere to local laws with respect to the approved access points and times of the day for delivery of materials.
The Sponsor utilizes in-house and contracted architects and technical specialists to design and develop commercial property and residential housing (condominium, stand-alone houses) projects. All property is designed in accordance with national standards, including the low income segment which is constructed according to minimum design standards for low-cost housing according to specifications from Caixa.
Civil works are designed and constructed according to Brazilian National building codes. The construction of new facilities is monitored by experienced project managers hired by the Sponsor to administer the construction of projects. Life and fire safety elements are designed and constructed according to Brazilian standards. High rise commercial buildings in some jurisdictions such as the State of Sao Paulo include life and fire safety design specifications which are consistent with mutually agreed life safety codes . Going forward, the Sponsor will be required to obtain a third party certification of the design and construction of new commercial buildings according to mutually agreed life safety codes.
- Potable Water – Commercial and residential real estate developments located in urban areas are typically connected to existing public water systems. Some peri-urban or rural developments, particularly low income housing projects, require a water treatment system. Such is the case in two low income housing projects under development in Altamira and Santarem, State of Para, where the Sponsor is installing water production wells and water treatment plants (with chlorination) which will be transferred to the local municipal government for operation upon completion.
-Supporting Infrastructure and Social Services – The construction of new projects in established urban areas must meet a series of previously described requirements for setbacks, constructed area limits, street access and other urban planning aspects. For low income housing projects, Caixa requires the Sponsor to set aside 1% of the project’s budget to construct education and health facilities and other social infrastructure also as required by the local planning authorities. Local authorities are responsible for the social insertion programs.
PS5: Land Acquisition and Involuntary Resettlement
The Sponsor acquires land on a willing buyer-willing basis, with transactions involving cash payment or swap deals in which the seller receives property in the proposed or other Sponsor developments. Land acquisition may involve land with existing infrastructure (housing, commercial buildings) or bare lands (generally previously used for agricultural purposes). The Sponsor has an informal policy of not acquiring lands with informal occupation, e.g., squatters.
Going forward, the Sponsor will develop a specific policy and protocol addressing potential economic displacement and physical displacement associated with all land acquisition. Such a policy and protocol will require the Sponsor to incorporate explicit consideration of the occurrence of economic and physical displacement in support of land acquisition into their land acquisition due diligence process, and where such risk exists, ensure that people adversely affected are adequately compensated. Compensation of economically and/or physically displaced people will occur in accordance with the requirements of PS5.
PS6 Biodiversity Conservation and Sustainable Natural Resource Management
The Sponsor primarily operates in the urban and peri-urban land markets in the States of Sao Paulo, Rio de Janeiro, and Minas Gerais. As such, the Company is not expected to encounter significant issues with regard to biodiversity conservation or sustainable natural resource management. Nonetheless a number of current projects are located in previously forested land such as Itaituba, State of Para. Going forward, and as described in PS1, the Sponsor will: (i) ensure that the land assessment includes appropriate assessment of biodiversity and natural resource management issues and the implementation of any recommended management measures to protect, conserve and otherwise enhance the conservation value of existing resources.
PS1: Social and Environmental Assessment and Management Systems
- Environmental and Social Assessment – The Sponsor complies with Brazilian requirements to conduct environmental and social impact assessments of its commercial and residential developments. The stepwise licensing process depends on the nature and location of the proposed project but may include, depending on the municipal jurisdiction, a series of feasibility studies in order to obtain preliminary permits and approvals including for example: approval of architectural design, including restrictions on height, set-backs, and limits on total area of construction; authorization for removal of natural vegetation; excavation permits; construction works permits; and authorization for connection to utilities. Depending on the extent and location of the proposed project, local authorities may also require more detailed environmental and social impact assessments prior to issuing construction and operating licenses (based on the regulator’s review of project impacts and mitigation measures). These assessments may consist of formal, detailed, Environmental and Social Impact Assessment (ESIA) studies or more streamlined Simplified Environmental Reports, depending also on the complexity and size of the project. Recently enacted legislation may also require completing studies of community impacts (Estudo de Impacto de Vizinhança (EIV)), to evaluate impacts on transit, landscape, and other aspects specific to urban areas.
The Sponsor will formalize an Environmental and Social (E&S) assessment procedure to be integrated into its existing land assessment and acquisition process. The procedure will define the minimum scope of E&S impact assessment applicable to each type of project (i.e. commercial or residential in urban, peri-urban or rural areas) taking into account the level of complexity and risk of the type of project. The defined scope will help ensure an adequate level of assessment of E&S risks and impacts that is consistent with IFC’s Performance Standards and that mitigates the risk of variability in the local E&S assessment requirements.
Assessment will include consideration of aspects of IFC’s Performance Standards relevant to the individual projects, including but not limited to: (i) site-specific pollution prevention and abatement screening (such as proximity to and potential impacts upon water bodies, past use of sites and resulting legacy environmental impacts), (ii) community health, safety and security including site vulnerability to landslide or flooding, traffic impacts and their management, and compliance with established standards governing structural integrity and life and fire safety; (iii) potential economic and physical displacement associated with land acquisition; (iv) Site-specific biodiversity assessment (if applicable) and; (v) potential discovery of cultural property.
- Management Program – The Sponsor has an established corporate level human resource management and administration system and processes addressing land acquisition, product development, a technical project development, construction management and sales and marketing. Construction managers are responsible for continuous management of construction schedules, costs and contractor (and sub-contractor) performance. Environmental and social (E&S) aspects are managed primarily as defined by applicable local, state, and national legal requirements using these requirements to guide and document the E&S management program. Brazilian regulations are comprehensive and in some cases are supported by detailed technical specifications and procedures, particularly with respect to aspects of occupational health and safety (OHS). In response to these requirements, the company prepares project-specific OHS management programs (PCMATs) which identify applicable occupational hazards and provide procedures for their control. These programs are complemented by a brief OHS procedure prepared by the company.
In order to continue to effectively manage the E&S aspects of its construction activities as the company grows, the Sponsor will formalize its E&S management processes and procedures into a documented E&S management program. The program will articulate an E&S policy and will include aspects such as review of the environmental assessment documents, contracting and supervision of consultants to assist in the preparation and monitoring of environmental and social management plans, and input into construction contracts to ensure compliance with environmental permit requirements.
- Organization – Responsibility for the Sponsor’s management of environmental, social, health, safety and labor aspects is fairly decentralized and shared among various departments and individuals of the organization. The implementation of environmental management requirements related to project development and construction are currently the responsibility of the project architects who ensure that all environmental licensing requirements are met as part of new project development and who are also responsible for their implementation during the construction phase. OHS aspects are the responsibility of an Occupational Safety Engineer who oversees corporate-wide construction projects and who is supported by Occupational Safety Specialist responsible for project-level oversight of OHS matters according to Brazilian legal requirements. Community engagement activities (described under the “Client’s Community Engagement” section below) are currently managed through the Sales Department (for complaints related to clients) and by construction site managers. As previously noted, ESIAs are usually prepared by external consulting firms.
Going forward, the Sponsor will strengthen the organizational structure currently responsible for implementation of the environmental, social, and health and safety management programs, by assigning sufficient human resources to implement current and future expansion needs as defined through the development of a formal E&S management program. This will include sufficient corporate level resources to monitor the management of OHS aspects across all of the Sponsor’s construction sites, including those outside the State of Minas Gerais as well as formal assignment of responsibilities for monitoring of environmental aspects in construction projects.
- Training – Given the nature of the Sponsor’s business activities, employee training programs are focused on the prevention of OHS risks in civil construction sites. As required by Brazilian legal requirements, the Sponsor has a defined training program covering aspects such as the identification of workplace hazards; the use of personal protective equipment and collective protection equipment; machine and tool safety; fall protection; electrical and fire hazards; and the roles and responsibilities of employers and employees. The company complements the basic training program with aspects specific to the work function (for example on scaffolding procedures for those responsible for this activity). Training is required at the time of employment and at the beginning of any construction project. A training registry is maintained of all company employees.
- Monitoring – The focus of the company’s monitoring is on the occupational, health and safety (OHS) aspects associated with construction activities. This includes a registry of all accidents, including those resulting in time away from work. Accidents registered are used to calculate frequency and severity rates according to local regulatory requirements. OHS monitoring also includes entrance, exit, and periodic medical exams as defined by a legally required occupational health medical control program (PCMSO). Additionally, internal site visits of construction projects are conducted by the corporate Occupational Safety Engineer to observe adherence to OHS procedures. Going forward, the Sponsor will monitor relevant environmental indicators, for example, construction materials waste generation and recycling and other construction activity environmental indicators, as applicable. OHS monitoring will further incorporate data of subcontractor accidents occurring in the Sponsor’s construction work sites.
- Reporting – The results of OHS monitoring activities are summarized into internal reports that are shared with company management who are also kept abreast on the status of environmental licensing processes, together with general project progress reports, by the architects responsible for these activities. Going forward, the Sponsor will prepare and internally distribute corporate monitoring information of a selected set of environmental, OHS, and social indicators. The Sponsor will further prepare and externally distribute a selected set of environmental and social indicators in a location / format easily accessible to interested members of the community. This information can be included in the company’s website or as a free standing Sustainability Report.
PS2 - Labor and Working Conditions
- Human Resource Policy and Management – At the time of appraisal, the Sponsor had approximately 1,900 direct employees, less than 10% of which are administrative and managerial staff (i.e. project planning, accounting, human resources management, etc) with the reminder dedicated to construction labor in the Canopus and Emcasa operations. Although the construction labor force fluctuates from year to year depending on the number and stage of construction projects (for example, there was a registered decrease of about 900 construction workers between 2010 and 2011) , Sponsor operations have grown significantly over recent years and are expected to continue to grow given the planned business expansion activities.
The company currently communicates employee rights and responsibilities through an Internal Employment Rules Handbook (Manual do Colaborador) and through employment contracts. The Internal Employment Rules Handbook defines company policy regarding general aspects of the company’s quality assurance program; safety and hygiene; maternity leave; holidays and vacation; justified absences from work; overtime benefits; proof of salary payment; use of uniforms; rules of use of means of communication (email and telephone); OHS; employment exit process; ethics; and dismissal. Individual employment contracts further define working hours and compensation applicable to the individual. In Brazil, the Consolidated Labor Law (CLT) comprehensively defines employee rights, substantially covering all aspects of Performance Standard 2. The CLT is widely divulged through the publication of pocket handbooks and is well known among the blue collar workforce across almost all industry sectors, including construction.
Nonetheless, going forward the Sponsor will amend its Internal Employment Rules Handbook in order to ensure consistency with IFC’s Performance Standard 2 in such aspects as: permissible wage deductions; legal maximums in hours of work; entitlement to benefits; non discrimination; and employees’ right to form and join workers’ organizations of their choosing and to bargain collectively with the employer.
- Grievance Mechanism – The company employees are currently able to lodge complaints internally through the Human Resources department and Company management, and externally through the public Labor Rights system. Going forward, the company will develop and implement an employee grievance process, published as part of the Internal Employment Rules Handbook to ensure consistency with IFC’s Performance Standard 2. The grievance process will allow: (a) any employee grievance by individuals or groups (including anonymous complaints) to be presented verbally or on in writing, without the risk of reprisals; documented and reviewed by company management and subject to a timetable for formal response and resolution; (b) workers the opportunity to meet with management, accompanied by a representative or companion; and (c) an appeal mechanism. The company will make the grievance procedure available to all existing and new employees at the time of hire.
- Worker’s Organizations – IFC found no evidence that the Sponsor restricts employees’ rights to freedom of association and collective bargaining.
- Non-Discrimination and Equal Opportunity – The Sponsor’s recruitment process gives priority to internal employees and apprentices by announcing all vacancies internally for a period of 15 days before external advertisement. Vacancy announcements do not include criteria such as desired age, sex or religion of candidates, or any other criteria unrelated to an applicant’s ability to fulfill the requirements of the position.
- Protecting the Workforce –Child labor is also strictly prohibited under Brazilian law and the Sponsor routinely verifies the age of job applicants by requirement proof of working age included in the workers’ social security cards. Employment contracts and Internal Employment Rules used by Sponsor clearly do not allow for circumstances that could be construed as forced labor.
-Occupational Health and Safety – The Sponsor has an OHS management program based on specific Brazilian regulatory requirements covering health monitoring (PCMSOs), project level occupational risk prevention programs (PCMATs), and applicable technical norms such as NR-18 for occupational health and safety in the construction industry. The project specific OHS management programs (PCMATs) cover such aspects as task-based risks for site preparation; unloading of cement and construction materials; excavations; concrete forms; electrical work; and finishing, to name a few. It also includes brief, simplified, procedures for the safe use and operation of hand tools, hoists, and elevators, for work in heights (including scaffolding), and for the safe use of chemical substances. Requirements for the Sponsor to come into compliance with IFC’s OHS requirements are described above under “Performance Standard 1.”
- Non-Employee Workers – The Sponsor subcontracts additional specialized services, particularly in commercial real estate developments, for such aspects as large excavation and leveling; rock blasting; demolition of old structures; damp-proofing; electrical and mechanical installations including elevators, escalators, and fire alarm and suppression systems; and cleaning and security services. All of these activities are performed based on short-term contracts and not for the exclusivity of the Sponsor.
PS3: Pollution Prevention and Abatement:
-Effluent Management - Typically for commercial and residential developments in urban areas, effluents are discharged to municipal sewage systems. This is also the case in low income housing developments located in urban or peri-urban areas where the Sponsor installs collection networks and, where necessary sewer pump stations, in order to connect to existing collection networks sometimes leading to municipal wastewater treatment plants. The Sponsor is also involved with projects in peri-urban areas without established sewage collection networks or treatment systems. In Brazil, such developments have historically used septic-tank and leach field based sanitation treatment and disposal systems. In small (<2,000 persons) peri-urban developments, the Sponsor will continue to adopt such technology subject to local approval and unless assessment shows a particular reason not to do so.
For large-scale peri-urban housing developments where a septic tank and leach-field sanitation solution is under consideration, such a solution will only be adopted if independent technical assessment determines that such a solution will not have adverse impact on human health or the environment. Such determination will follow site specific assessment that would typically consider cumulative impacts of large numbers of leach fields through a quantitative analysis including infiltration modeling and evaluation of potential quality effects to surface water and ground water (e.g., nutrients / nitrate contamination), contaminant fate and transport study, taking account of location and characteristics of the closest sensitive receptors (including water wells or other water collection systems), assimilative capacity of the receiving water body; and uses of the receiving water body. In these large-scale peri-urban developments, unless analysis such as described above demonstrates that a septic tank and leach field technology does not have an adverse impact on human health or the environment, then the Sponsor will design and construct the development to incorporate a sewage collection network, and will construct, or cause to be constructed by others, a sewage treatment system for the development. The Sponsor indicates that under this situation, the operation and maintenance of the wastewater treatment infrastructure would be transferred to the local municipality as is the case in a low income project with 3,000 units in Santarem, State of Para, where the sewage treatment plant for the low income housing project will be transferred to the local municipal government upon completion.
In addition, in any development that utilizes a septic tank and leach field sanitation solution, such as the recently constructed project in Itaituba, State of Para, or a planned project in Gurupi, State of Tocantins, the Sponsor will educate home purchasers of the need to arrange regular servicing of septic tank systems, typically every two years. This will be done by introduction of the homeowner or homeowners’ condominium association as relevant to an approved management company or through coordination with local authorities responsible for receiving and managing septage waste.
- Wastes - During the construction of new projects, the Sponsor follows the environmental conditions of the environmental license and any other local legal requirements which include management of excavated materials from civil works site preparation (e.g. soil and rock materials); miscellaneous organic and inorganic domestic waste from work site services and offices (e.g. food, paper, and plastics); equipment shipping materials (e.g. wood crates, cardboard, etc); and construction equipment maintenance wastes (e.g. waste lubricants, used oil filters, etc), and the use of portable toilets.
- Ambient Noise – During the construction phase, ambient noise concerns are managed by proper maintenance of construction equipment exhaust noise controls and through restrictions on construction site operating hours.
- Energy Conservation – Energy conservation considerations are mainly included in the design of commercial real estate (high rise office buildings). These include energy efficient cooling systems; energy efficient lighting fixtures, including motion sensors in some common areas; and, in a recent high-rise office building, use of elevators with regenerative brake systems. In the residential segment, the Sponsor’s inclusion of energy conservation measures in the design are mainly limited to solar water heaters, although these are mainly used in the middle to high income constructions. In low income houses, this equipment is only used if Caixa, the public sector finance institution backing these projects, approves and covers the cost increase.
PS4: Community Health, Safety and Security
- Infrastructure and Equipment Safety - During the construction phase, the principal risk to health and safety of the community typically consist of traffic and pedestrian safety from the transport of construction materials, equipment, and workers to and from the construction sites and potential for structural damage to local housing located adjacent to transport routes. The Sponsor requires construction contractors to adhere to local laws with respect to the approved access points and times of the day for delivery of materials.
The Sponsor utilizes in-house and contracted architects and technical specialists to design and develop commercial property and residential housing (condominium, stand-alone houses) projects. All property is designed in accordance with national standards, including the low income segment which is constructed according to minimum design standards for low-cost housing according to specifications from Caixa.
Civil works are designed and constructed according to Brazilian National building codes. The construction of new facilities is monitored by experienced project managers hired by the Sponsor to administer the construction of projects. Life and fire safety elements are designed and constructed according to Brazilian standards. High rise commercial buildings in some jurisdictions such as the State of Sao Paulo include life and fire safety design specifications which are consistent with mutually agreed life safety codes . Going forward, the Sponsor will be required to obtain a third party certification of the design and construction of new commercial buildings according to mutually agreed life safety codes.
- Potable Water – Commercial and residential real estate developments located in urban areas are typically connected to existing public water systems. Some peri-urban or rural developments, particularly low income housing projects, require a water treatment system. Such is the case in two low income housing projects under development in Altamira and Santarem, State of Para, where the Sponsor is installing water production wells and water treatment plants (with chlorination) which will be transferred to the local municipal government for operation upon completion.
-Supporting Infrastructure and Social Services – The construction of new projects in established urban areas must meet a series of previously described requirements for setbacks, constructed area limits, street access and other urban planning aspects. For low income housing projects, Caixa requires the Sponsor to set aside 1% of the project’s budget to construct education and health facilities and other social infrastructure also as required by the local planning authorities. Local authorities are responsible for the social insertion programs.
PS5: Land Acquisition and Involuntary Resettlement
The Sponsor acquires land on a willing buyer-willing basis, with transactions involving cash payment or swap deals in which the seller receives property in the proposed or other Sponsor developments. Land acquisition may involve land with existing infrastructure (housing, commercial buildings) or bare lands (generally previously used for agricultural purposes). The Sponsor has an informal policy of not acquiring lands with informal occupation, e.g., squatters.
Going forward, the Sponsor will develop a specific policy and protocol addressing potential economic displacement and physical displacement associated with all land acquisition. Such a policy and protocol will require the Sponsor to incorporate explicit consideration of the occurrence of economic and physical displacement in support of land acquisition into their land acquisition due diligence process, and where such risk exists, ensure that people adversely affected are adequately compensated. Compensation of economically and/or physically displaced people will occur in accordance with the requirements of PS5.
PS6 Biodiversity Conservation and Sustainable Natural Resource Management
The Sponsor primarily operates in the urban and peri-urban land markets in the States of Sao Paulo, Rio de Janeiro, and Minas Gerais. As such, the Company is not expected to encounter significant issues with regard to biodiversity conservation or sustainable natural resource management. Nonetheless a number of current projects are located in previously forested land such as Itaituba, State of Para. Going forward, and as described in PS1, the Sponsor will: (i) ensure that the land assessment includes appropriate assessment of biodiversity and natural resource management issues and the implementation of any recommended management measures to protect, conserve and otherwise enhance the conservation value of existing resources.
Stakeholder Engagement
Potentially affected communities in the Sponsor’s project may include local residents and business owners located in proximity to the residential or real estate developments as well as the Sponsor’s clients and future occupants of the projects developed by the Sponsor. Engagement with clients is conducted through the property sales function which provides channels of communication before and after the sale in order to address concerns about the quality of the construction product. This relationship is managed through the sales department and includes a contact through the company’s website at: http://www.canopus.com.br/atendimento/faleconosco.asp. The Sponsor’s community engagement with local residents and business owners is limited to what is required by the local jurisdictions to obtain the environmental license and in some cases may include organization of public audiences to explain the nature of proposed projects to interested parties, including potentially affected communities. During the construction process, community engagement is informally managed by the engineer in charge of the project who is present at the site during construction work hours and who is responsible for receiving and addressing complaints. The Company’s name is prominently displayed in the exterior of all projects under construction. Also, in accordance with local regulations in Brazil, construction permits must also be posted in a visible area outside of the construction site indicating the name of the project Sponsor and the engineer in charge.
Going forward, the Sponsor will develop and implement a formal community engagement and grievance process consistent with IFC’s Performance Standards requirements.
Going forward, the Sponsor will develop and implement a formal community engagement and grievance process consistent with IFC’s Performance Standards requirements.
Maury Fonseca Bastos, Financial Director (maury@canopus.com.br)
Rua Maria Luiza Santiago, 200 – 23º floor – Santa Lucia
Belo Horizonte, MG – Brazil – 30360-740
Tel; (31) 3281-7070
Fax: (11) 3284-7070
Rua Maria Luiza Santiago, 200 – 23º floor – Santa Lucia
Belo Horizonte, MG – Brazil – 30360-740
Tel; (31) 3281-7070
Fax: (11) 3284-7070
Environmental & Social Action Plan
| Canopus(31059) Supervision Disclosure Snapshot – Version 2 | ||||
|---|---|---|---|---|
| Description | Anticipated Completion Date | Status | Comments | Completion Date |
| Appoint qualified technical expertise to assist the Sponsor in developing a formal environmental management program, including detail procedures, so that it covers key aspects in IFC Performance Standards focusing on the following: - Articulation of Corporate Environmental and Social Policy; - Environmental and social impacts assessment procedure, including technical scope, to be applied to the new projects in the Company’s pipeline; - Community engagement and grievances process - Effluent management - Life and Fire Safety - Emergency preparedness and response plans - Land acquisition and involuntary resettlement - Biodiversity conservation - Monitoring and reporting | 16-Feb-2012 | In progress | Under discussion with IFC Client | |
| Designate or contract a corporate environmental officer responsible for oversight of the preparation and implementation of a the aforementioned Management Program Contract sufficient Occupational Safety Engineers to ensure adequate oversight, including field audits, of all construction projects across the country. | 28-Feb-2012 | Completed | Completed | 3/31/2016 |
| Develop and implement a robust Environmental, Health, and Safety (EHS) audit program of construction projects to identify and correct occupational and environmental hazards. The audit program should include documented summary of findings and corrective action plans | 31-Oct-2012 | Completed | Completed | 1/1/2016 |
| Prepare internal and external reports on key indicators of environmental, occupational health and safety, and social performance. External reports will be disclosed annually in the company’s external website. | 31-Oct-2012 | In progress | Under discussion with IFC Client | |
| Review and amend the Internal Employee Rules Handbook to be consistent with IFC Performance Standard 2 requirements. Publish the HR policy in a handbook or another format for easy distribution to all existing and incoming workers. | 31-Oct-2012 | Completed | Completed | 1/1/2016 |
| Develop and implement employee grievance process consistent with IFC Performance Standard 2 requirements. | 31-Oct-2012 | In progress | Under discussion with IFC Client | |
| Monitor accidents of subcontractors’ employees during construction projects as required by Brazilian Law (this includes accidents occurring while working on site or en route to work. Account for these accidents in the Sponsor’s occupational accident statistics, differentiating between the Sponsor’s and the subcontractor contribution to these rates. Amend the accident investigation procedures to include a root-cause analysis and a concrete set of corrective and preventive actions that shall also be communicated to all employees as part of on-going training programs. | 31-Oct-2012 | Completed | Completed | 1/1/2016 |
| For large-scale, medium-to-high density peri-urban housing developments of greater than 2,000 persons that are not connected to the municipal waste water treatment system: (i) undertake analysis to identify and quantify potential adverse impacts of septic tank and leach field sanitation solutions; (ii) utilize such systems only if the analysis demonstrates an absence of such adverse impacts; (iii) when septic tank systems are adopted, provide contacts to homeowners of appropriately qualified system maintenance contractors; (iv) in other cases, construct developments with sewage collection networks, and construct or cause sewage treatments systems to be provided for the developments. | 31-Oct-2012 | Completed | Completed | 1/1/2016 |
| Life and Fire Safety System Design (Commercial Buildings) For all new commercial buildings, engage professional services of a qualified Life and Fire Safety Engineer mutually acceptable to prepare Master Plan (engineering design) and post construction inspections to verify that the system was installed as designed. Life and fire safety design shall be responsive to mutually agreed life safety codes. Certification of Life and Fire Safety System Design Provide third party certification by a qualified professional mutually acceptable that the design and construction of life and fire safety systems for new constructions comply with mutually agreed standards. Certification of Life and Fire Safety System Construction The designer shall provide a professional certification affirming that facility construction faithfully incorporates all elements of the life and fire safety design previously certified to IFC. | 01-Jan-2021 | In progress | Under discussion with IFC Client | |
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.